Posted by:
Brother Of Jerry
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Date: June 18, 2019 02:07PM
I stumbled across an article by Pamela Druckerman about inheritance laws, and it is slightly more complicated than I realized.
https://www.nytimes.com/2019/05/28/opinion/johnny-hallyday-inheritance.htmlFrom the article:
The court was merely announcing whether it had jurisdiction over Mr. Hallyday’s estate or whether the case should be heard in California, where Mr. Hallyday lived during many of his final years. But at stake was a question that divides French and American law: Should you be allowed to disinherit your own kids?
In most of the United States, you can. Mr. Hallyday opted for the American approach: His Californian will names his fourth wife and widow, Laeticia Hallyday, as his sole heir. The couple’s two adopted daughters would presumably share in the bounty, which is estimated in the tens of millions, plus future royalties. But Mr. Hallyday’s two older children, from previous wives, would inherit nothing.
Under French law, such an arrangement is impossible. A large part of a parent’s estate — starting at 50 percent if there’s one child and reaching 75 percent for three or more — must be divided equally among the children. This includes “illegitimate” heirs and those from prior marriages, known collectively as “children from another bed.” (Louisiana, part of a former French colony, has a similar rule known as “forced heirship.”)
BTW, the court ruled that French law controls. Mr Hallyday was a French citizen, lived most of his life in France, and earned almost all of what is now his estate in France. He was a French rock and roll icon.